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Now is your chance to remove unnecessary rules and costs/VOR airspace thread merged

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Now is your chance to remove unnecessary rules and costs/VOR airspace thread merged

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Old 23rd Jul 2007, 02:54
  #141 (permalink)  
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.. comon Dick, yer back in the country .... post the info (in full)
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Old 24th Jul 2007, 05:32
  #142 (permalink)  
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... this thread Dick ... comon post the stuff you sent!
.
If you won't we will deduce why
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Old 25th Jul 2007, 00:37
  #143 (permalink)  
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Following is everything that was posted that removes unnecessary rules and costs. This has been passed on to the Civil Aviation Safety Authority.

Flying Operations

Oxygen requirements
In Australia oxygen is required above 10,000 feet in Australia. In the US and other leading countries oxygen is required above 12,500 feet, with an allowance to fly up to 14,000 feet for 30 minutes without oxygen. This saves up to $1 million per year.

Non-tower straight in approaches
In Australia there is a current requirement to be established on a 5 mile final to conduct a straight-in approach at non-tower airports. Joining on base is also not permitted. This adds to costs compared to the FAA requirements.

Part 135 – Air Taxi
Australia lacks a Part 135 Scheduled Air Taxi category and instead requires higher costs as aircraft of 9 passengers and below on a scheduled service are designated as RPT. . Over 50 Australian regional airports have lost their air services in the past 20 years. Many could get a service back again.

Single engine piston charter
Single engine piston aircraft cannot conduct IFR charter flights or Night VFR charter flight in Australia. This is possible in the USA, saving a large amount of money

VFR aircraft above FL200
VFR aircraft are restricted from operating above FL200 in Australia. No similar restriction exists in North America. There are times when an aircraft could fly at FL245 and save enroute charges and fuel.

Helicopter low flying
Low flying requirements are more restrictive in Australia, meaning extra costs for endorsements or modification of AOCs.

Aerobatic base height
In Australia a pilot with an aerobatic rating must not do aerobatics below 3,000 feet without a waiver. Not many people are qualified to issue these flight tests and waivers, meaning extra expense to travel to the location of a qualified person, and extra expense to pay for the training/testing. In the USA pilots with an aerobatic rating may conduct aerobatics down to 1,500 feet. Note that many aerobatic training aircraft do not perform well at higher altitudes, resulting in more time and fuel to climb back to altitude between manoeuvres. Aerobatic competitions also have a base height of 1,500 feet and below, so anyone wishing to compete must obtain a waiver.

Simplified AOCs
AOCs should not take 6 to 12 months and cost $50,000. Australia could harmonise with the simpler US system. AOCs should be available within days, not months.

AOC renewals
AOCs require regular renewals. Other leading aviation countries are not as onerous.

Aircraft on AOCs
In Australia there are separate charges to add a light single or a twin to an AOC. This is not required in the USA under the FAA rules.

Joy flights – AOCs
In Australia joy flight operators require an AOC. Joy flights within 25 miles do not require an AOC under the FAA requirements. Harmonisation could lead to savings.

Airworthiness

ADs duplicated from manufacturer’s service bulletins
Some Australian ADs actually duplicate manufacturer maintenance requirements while some mandate one aspect of a manufacturer’s supplementary maintenance document.

Unique Australian ADs
There are many unique Australian ADs which add to costs but do not measurably add to safety.

i. AD/GEN/37 – Emergency exit to be checked every 6 months. The FAA requirement is every 3 years or as per manufacturer’s maintenance system.
ii. AD/INST/9 – Instruments in IFR aircraft must be removed from the panel every 3 years to be tested. There is no similar AD in the USA.

Cessna 400 and other aircraft spar inspection
The spar inspection is required at 8,500 hours with a cost of $50,000 to $100,000. A similar inspection is not required by the FAA.

Expert Airworthiness Approval (Section 7.1)
Australia has a requirement for an Expert Airworthiness Approval (Section 7.1). There is no similar requirement in the USA for US pilots when ordering parts from overseas.

Unique certification requirements
In Australia unique certification requirements still exist, despite a Government decision to harmonise – eg extra registration letters painted under the wing double the cost of signwriting registration letters.

Helicopter maintenance/training
Helicopters over 2,750 kg must be maintained to “Transport Class A” regardless of complexity. There is also a doubling of hours required for endorsement training compared with Class B helicopters. If rationalised with the FAA system there would be savings.

A&P System for aircraft maintenance
This system for aircraft maintenance personnel requires less training, and therefore lowers the cost of maintenance compared to the Australian LAME system.

Annual inspections
Australia changed from a three year airworthiness inspection to an annual system but did not harmonise with the FAA requirement.

Maintenance approval for flying training organisations
Flying training organisations need a separate maintenance approval. This is not required in other leading aviation countries.


Airspace


Free in G

In Canada and the UK, an aircraft can fly IFR in Class G without a directed traffic service and not pay an enroute charge. Australia should harmonise with this as per the NAS policy.

Terminal airspace size
Larger Class D and Class C airspace around Australian towers means that greater diversions are required by aircraft avoiding the airspace.

Restrictive Military Airspace
In Australia aircraft are required to fly extra distances to avoid military airspace. In the USA and other countries they have Military Operation Areas, which aircraft can track through if military flying training or similar activities are taking place.

UNICOMs in lieu of Certified Air/Ground Operators
Australian Certified Air/Ground Operators need to have held an air traffic control or flight service licence. In the USA, any skilled person can operate the UNICOM, with far lower costs.

Charting
Simple Class D airspace in the USA means that a Visual Terminal Chart is not required for Class D. Many hundreds of thousands of dollars could be saved by showing the simplified NAS Class D airspace on the Visual Navigation Chart rather than printing extra Class D VTCs.

Local ownership

Rescue and fire fighting/air traffic control towers
The FAA saves up to 50% with their contract tower program. Major savings could be achieved here with local ownership.

Flight Instructors/Training/Licensing

Flight instructors – AOC
Flight instructors are required to operate under an AOC in Australia. In the USA, an AOC is not required, resulting in major savings and encouraging experienced pilots to put their knowledge back into the industry.

Flight instructors – hours on type
Australia requires an instructor to have 10 hours on a type specific twin, even if the instructor has hundreds of hours on other twins.

IFR helicopter instruction
In Australia IFR helicopter instruction must be done in an IFR helicopter. In the USA most IFR helicopter training is done on helicopters such as an R22. Costs are saved and safety is improved as more instrument ratings exist.

Student licences
Suggestion to allow CFIs to issue student licences so they can go solo when ready – not after Nav 7! This is a unique Australian requirement.

Student pilot approval - ASIC
Australia requires an ASIC with all of the costs and delays. The US simply requires that the instructor ascertains that the pilot is a US citizen by checking the students’ passport or birth certificate and noting this in the training records.

ICAO licence holders
Australia has a requirement for overseas ICAO licence holders to get a certificate of validation. Flight instructors could approve ICAO licence holders to fly privately here as per ICAO countries.

Biennial Flight Reviews
In Australia holders of fixed wing, helicopter and recreational licences are required to do three separate BFRs – one for each category. In the USA only one is required.

Instrument ratings
In Australia pilots are issued with a single engine or multi-engine instrument rating, with the multi-engine rating requiring 20 hours in multi-engine aircraft. In the USA there is no such requirement. If instrument rating training is conducted in a single engine aircraft, the pilot can still fly multi-engine IFR. In Australia pilots also qualify for each type of approach, which is listed on their licence. In the USA this is not done – a pilot just has an instrument rating. Harmonisation could result in lower costs and more pilots undergoing instrument training, therefore improving safety.

IFR recency requirements and annual renewals
Australia has recency requirements such as an ILS every 35 days. In the USA this is once every 6 months. Harmonisation could lead to substantial savings. Australia also requires an IFR renewal every 12 months. The US does not – as long as recency has been complied with. The helicopter instrument rating renewal can only be taken in an IFR rated helicopter in Australia. There is no requirement for the renewal in the USA. Even in Australia a Night VFR BK117, with IFR equipment which could be used to maintain approach currency, can not be used for a renewal.

Endorsements
A reduced number of endorsements are required under the FAA system, saving a substantial amount of money.

Exams

Exam cost
Presently the cost of exams in Australia is about 10 times the cost of sitting for similar exams under the FAA system.

Flying schools conducting exams
Flying schools can conduct cyber exams up to ATPL level in the USA – this is not permitted in Australia.

Security

Aviation Security Identification Card (ASIC) costs
In the USA pilots can use existing identification such as a pilot licence and a driver’s licence with a photograph. A separate ASIC is not required. Many millions of dollars would be saved if we harmonised with the US procedure.
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Old 25th Jul 2007, 00:55
  #144 (permalink)  
 
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Dick,

I have to admit that I am starting to agree with you.
Especially about the renewal of an instrument rating each year.
Re. the military airspace - there are lighty lanes available now. (a la ESL, WLM)
When are you implimenting these ideas?
And when are we getting rid of the ridiculous $75 (previously $130) charge for CASA to process a medical (ie rubber stamp)

Cheers
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Old 25th Jul 2007, 06:51
  #145 (permalink)  
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Thankyou for posting the info
Airspace
.
Free in G
In Canada and the UK, an aircraft can fly IFR in Class G without a directed traffic service and not pay an enroute charge. Australia should harmonise with this as per the NAS policy.
.
Terminal airspace size
Larger Class D and Class C airspace around Australian towers means that greater diversions are required by aircraft avoiding the airspace.
.
Restrictive Military Airspace
In Australia aircraft are required to fly extra distances to avoid military airspace. In the USA and other countries they have Military Operation Areas, which aircraft can track through if military flying training or similar activities are taking place.
.
UNICOMs in lieu of Certified Air/Ground Operators
Australian Certified Air/Ground Operators need to have held an air traffic control or flight service licence. In the USA, any skilled person can operate the UNICOM, with far lower costs.
.
Charting
Simple Class D airspace in the USA means that a Visual Terminal Chart is not required for Class D. Many hundreds of thousands of dollars could be saved by showing the simplified NAS Class D airspace on the Visual Navigation Chart rather than printing extra Class D VTCs.
… I don’t disagree with the first one .. that aside …. OK, so in the airspace context you forwarded this, which is clearly your view/s rather than those put forward in this thread … so what was the point of it?
.
Also, a question arising … did you couch this input as your opinion/s or the industry’s opinion/s??
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Old 25th Jul 2007, 10:49
  #146 (permalink)  
 
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Dick, ABSOLUTELY SPOT ON!!!!
After 12 Yrs here in USA I am not looking forward to putting up with user fees and a staggering number of overly complex rules and regs covering all the areas in your post above and many others.
There is more aviation going on and aircraft here in California in any single day alone than all of Australia put together and the system works extremely well coping with some of the worlds busiest and most complex airspace, mountainous terrain with peaks to 14,500' and extensive ranges over 10,000', snow and ice in winter and other severe weather.

Australia should be ashamed and disgusted of our system which is no safer than the system overall here in the USA but costs GOD only knows how much more to fund and keep bureaucrats employed and others in the industry who arrogantly assume Australia is far superior to everyone else because we insist on re inventing the wheel, and badly at that and making everything as complex and expensive as possible.

After studying the AIP at the beginning of the yr I saw rules, regs that have not changed in any way in 12yrs. Some are still word for word the same overblown ,overly complicated , hard to remember novels they were since the early 1980s when I started flying.

It cost me $600 AUD in total costs and fees to get my ASIC and a Class 1 medical reissued and I have still to do my ME CIR renewal and DG course just to be ready to look for work in Aust again.

Let's all work to do what we can to finally overhaul our skies and our laws and procedures.
Flying in Australia with a US style system in place(even with our lack of radar coverage) should be a breeze compared to what I remember and to what I expect to face again next month.
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Old 25th Jul 2007, 10:58
  #147 (permalink)  
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I have been following this thread with great interest and Mods don't normally express opinions ..... but in this case I think Dick Smith has summarised all the posts exceedingly well.

You may not agree with everything on his agenda, but you must agree the vast majority make sense and very well reflect the opinions posted on PPRuNe.

I hope he succeeds!

Hello Canberra. Anyone listening???
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Old 25th Jul 2007, 11:18
  #148 (permalink)  

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Dick on your above points covering,

Biennial Flight Reviews

Instrument ratings

IFR recency requirements and annual renewals

Endorsements,


you need to differentiate between what the regulator requires and what Insurance Companies demand to extend cover to an individual.

I very much doubt the savings in these areas are anything like significant. Insurance costs in the US varies enormously depending on what extended training courses an individual has completed...as an example someone transitioning from a simple aircraft, say 172, to a Bonanza may have to complete 20-30hrs cross country on the Bonanza with a suitably qualified instructor before coverage is extended at all let alone affordable coverage.

Hardly a month goes by when I don't read on the various industry websites I subscribe to about a US PPL holder CFITing while flying an ILS etc etc.

Here is a typical example...if you don't think this impacts insurance premiums you're dreaming...would the overly burdensome Australian requirements have avoided this accident?

http://www.avweb.com/news/probablecause/194578-1.html

There is a price to pay for light regulatory hands...the old story, no free lunch.

I think you are naive to suggest huge savings in some of the points you raise above...other points you make above would surely be an improvement.

It seems to me though that reading your list above I see your old drum hidden (badly) among the items...what a surprise.
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Old 25th Jul 2007, 11:25
  #149 (permalink)  
 
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Dick,

A good summary, well done.

In respect of your request for VFR aircraft to be allowed to fly above F200... they will be required to be equipped with a working transponder that is required to be switched on... won't they?
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Old 25th Jul 2007, 12:28
  #150 (permalink)  
 
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Terminal airspace size
Larger Class D and Class C airspace around Australian towers means that greater diversions are required by aircraft avoiding the airspace.
I think I have followed this thread fairly well, but I don't think this has been raised by anyone. I really don't think this is an issue
Class D airspace around regional towers is just an appropriate size for the use. I remember when we had 16nm radius down to the ground, now 6nm.
Why avoid the airspace? We do our best to facilitate all flights, arriving, departing, transit. It may be that going around the CTA steps / Control zone might end up quicker, maybe not. Never hurts to ask, just don't wait til the last second to call, give us a bit of thinking time.
It also improves things if you can make the initial call with callsign and advise if inbound or transit, wait for an answer, then go ahead with full details. This achieves a couple of things. You get the controllers attention, they know what colour strip to put your details on, their mind begins to add you into the traffic picture and it reduces repeated transmissions.
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Old 25th Jul 2007, 12:48
  #151 (permalink)  
 
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Good bits there, Dick. However, you forgot to ask about why the landlord isn't keeping a tight rein on the tenants to stop them pouring on unneccessary charges and costs on their customers and sub-leasees at our major airports and GAAPS.

A close eye on some developments over the last few years could have saved a runway or two too!
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Old 26th Jul 2007, 01:12
  #152 (permalink)  
 
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Either support or don't have an opinion on most of your list, but will comment on the following.

VFR aircraft are restricted from operating above FL200 in Australia.

No they are not, but a badly expressed rules says they can't without CASA approval. CASA grants such approval if the aircraft is fitted with an IFR calibrated altimeter. They have also permitted glider flights without such, including class A airspace, subject to LOA with ATS. I agree this is a silly rule though.

No similar restriction exists in North America. There are times when an aircraft could fly at FL245 and save enroute charges and fuel.

Erm, not permitting flight above FL180 is an improvement over there hey????? The NAS changes are a bigger impediment to VFR access to high level airspace than this rule. Prior to the NAS 2B changes VFR could get a clearance up to FL285. Now they are permitted (subject to the above), but not in the class A base FL180 environment that coincides with the best radar coverage in the country - the area best able to deal with such flights. This is also the airspace that most closely resembles the US model, do you want to roll it back to class A with a base of FL245? If so, do you have any inkling as to what you will be demanding next week?

In Canada and the UK, an aircraft can fly IFR in Class G without a directed traffic service and not pay an enroute charge. Australia should harmonise with this as per the NAS policy.

I thought the NAS policy was to have class E airspace corridors 4 nm wide with a base of 1,200 FT AGL, and down to 700 FT AGL in terminal areas anywhere an IFR aircraft is likely to make an approach. The knock on for this in the US is no IFR aircraft can move anywhere without a clearance. Where do you envisage IFR exhibiting these wondrous freedoms, or is this more rollback? Isn't this the core of LLAMP you fought so valiantly against a short time ago??? You could have had this already and it is partly your fault it has not happened.

Larger Class D and Class C airspace around Australian towers means that greater diversions are required by aircraft avoiding the airspace.

The justification in the US documents for their skimpy terminal areas that aircraft within constantly brush the edges of is that they are separated with any IFR aircraft in the class E airspace surrounding. Reducing the size of D & C airspace without the mitigators present in the US has the potential to decrease safety, particularly with your 'free in G' mates happily brushing the other side of the boundary.

Do what you like to the vertical extent of such airspace, I'm sure OAR will prove it is safe before they implement it.
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Old 26th Jul 2007, 02:27
  #153 (permalink)  
 
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Aerobatic base height
In Australia a pilot with an aerobatic rating must not do aerobatics below 3,000 feet without a waiver.
About 5 years ago the CASA draft of Part 91 proposed 1500 ft however the response they got from the Australian Aerobatic Club and others was summarised as "Many respondents indicated that the minimum height for aerobatics should be initially set at 3000 feet and not 1500 feet as proposed in the regulation."
I haven't taken much interest in Parts 61 and 91 for ages due to the rate of progress but I believe that 1500 ft is now back in the draft.
As Pogo said, "We have met the enemy.... and he is us".
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Old 26th Jul 2007, 02:42
  #154 (permalink)  
 
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Dick,

Well summarised: thank you for your efforts to date
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Old 26th Jul 2007, 03:31
  #155 (permalink)  

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putytat

May I requote your post from earlier in the month as I am only just catching up with my reading.

From its content I would guess you may have been as close as I to the NAS2b implementation and its attempted replay with 2c.

There was a real example of unnecessary rules and costs. I never saw the clusterfcuk actually costed but it had to be more than several hundred thousand dollars chasing an idiotology agenda.

Just so those who seem to have a comprehension problem and are terminally resistant to learning from past mistakes here's how change is affected......thank you putytat. Eeeeeerm except for the little Kevie and his heavies maybe. And it will be great fun for all if Marn Fern gets the Aviation portfolio.


1. Vote 1 - Kevin Rudd

2. Raise every issue however insignificant at every industry hazard identification workshop forum run on NAS reforms and ensure that the risks are identified correctly and thoroughly. Ensure that identified risks have documented mitigators and safety requirements that must be met prior to implementation where necessary.

3. Raise every issue however insignificant at every industry hazard identification workshop forum run on NAS reforms to be included in any cost benefit analysis that must be completed by the change proponent. Ensure that these issues are costed correctly and ensure that the change proponents are required to provide detailed information on any CBA to the workshop participants post the event. Ensure that the participants are periodically advised of any amendments to this analysis right through to implementation.
Request information from the change proponent up front regarding exactly what level of CBA would be acceptable for a change to be approved and progressed.

4. Ensure points 2 and 3 are included in the PIR. Ensure that the PIR is firmly programmed into the initial project timeline. Ensure that the same participants will be involved all the way through the process to the PIR stage.

5. Analyse the project plan and timelines to ensure that the appropriate methods of promulgation are planned to be used (unlike CTAFs where a 52 page AIP SUP was used to hand amend AIP book).

6. Ensure that the same participants are fully involved in the creation of the relevant training and education package, and ensure that the content is adequate for the level / type of change.

7. Ask as many questions as necessary regarding the compliance with ICAO of any change proposal.

8. Ensure that the participants sight and approve the required changes to the relevant AIS documentation prior to printing and distribution.

9. Resist at all costs the attempts to use TCAS as a risk mitigator (refer point 7).

There's a starting point, but let's hope the ALP has other ideas and agendas more important than these insignificant reforms that will not add anything to the Aus aviation industry.
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Old 28th Jul 2007, 22:03
  #156 (permalink)  
 
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Dick,

Re the hours for endorsement training, it appears that the (UK) CAA is proposing a reduction in their requirements. Discussion in a thread on Rotorheads:

The letter references an AIC, which directs readers to a JAA website. Sorry to be unhelpful, but I don't have the letter in front of me just now.
For SEH, the LTE for a 3 hour minimum conversion time for SEP and SET, which had modified the JAR-FCL 5 hour courses, is now replaced in FCL-2 Amendment 6.
The SEP to SEP and SET to SET minimum flight time is now 2 hours in each group, EXCEPT the R22 and R44: which go back to 5 minimum. (And no credit if R22 to R44 or vice-versa.)
The MEH (MET to MET) is now, broadly, 3 hours minimum flight time.
Add the time for an LST to the above.
There are other changes in AL6 too, but I hope this answers your question.
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Old 31st Jul 2007, 06:44
  #157 (permalink)  
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Here’s another cost saving:

Night VFR
Pilots in the USA all do 3 hours dual training at night as part of their PPL. After passing their PPL flight test they are then qualified to fly at night. In Australia pilots must do a Night VFR rating of 10 hours dual (say, a cost of $2,000), including 2 hours of dual night circuits, 5 hours of dual night navigation training and at least one 3 hour navigation exercise of 100 miles or more. They must then pass a test at night. The result is that Australian private pilots have no night flying experience at all, unless they undergo extra costly dual training. Many do not complete this training due to cost – thus lowering the level of safety.
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Old 31st Jul 2007, 08:16
  #158 (permalink)  
 
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The band 'The Dead Kennedys' suddenly springs to mind for some reason....
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Old 31st Jul 2007, 08:25
  #159 (permalink)  
 
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"Pilots in the USA all do 3 hours dual training at night as part of their PPL. After passing their PPL flight test they are then qualified to fly at night."

Sounds to me like a quick way to end your life cycle!

Dr

PS: Dick, tell me you are not serious! You're not are you? Dick?

How about 3 hours dual training for a PPL. That would save some money. Do it at night in IMC and throw in a night rating AND an IR!

Last edited by ForkTailedDrKiller; 31st Jul 2007 at 11:27.
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Old 31st Jul 2007, 08:35
  #160 (permalink)  
 
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Creamy

Dick, there is a minimum standard that we really shouldn't play with lest someone trys to push their limited skillset and ending up bending something, or worse.

For my money, I do not want a devalued CIR, thankyou very much!
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